Individual / Organisation name: Suzuki Australia Pty Limited

What state/territory are you from? Victoria (operating nationally)

Public Discussion Paper:
Review of Design and Engineering Controls for Improving Quad Bike Safety

Public Comment Response Form

Complete and submit this form by 5:00pm AEST 28 SEPTEMBER 2012 to

Suzuki Australia Pty Limited (Suzuki) is an importer of motor vehicles, motorcycles and All Terrain Vehicles (ATVs) in all States and Territories in Australia (except Queensland).

Suzuki is also an active member of the Federal Chamber of Automotive Industries (FCAI) and supports the submissions made by the FCAI in response to the Public Discussion Paper.

Since the introduction of the ATV to Australia Suzuki has been involved in a number of ATV safety initiatives including, but not limited to:

1.  ensuring that all ATVs sold by it comply with the voluntary and "world's best" ANSI/SVIA design standard (2007 and 2010);

2.  participating in a number of workshops, discussions and consultation with industry and expert bodies with a view to investigating and considering practical strategies and effective controls to improve the safety of ATVs.

3.  the preparation and presentation of detailed submissions and recommendations for the lengthy Coroner's Inquiry in Victoria and Tasmania; and

4.  the preparation of detailed submissions and recommendations for the Parliamentary Inquiry into the Cause of Fatality and Injury on Victorian Farms.

Through these initiatives Suzuki has consistently supported and promoted proven safety measures including the mandatory wearing of helmets, comprehensive training and appropriate use of ATVs, particularly the banning of children under the age of 16 from using adult-sized ATVs and the carrying of pillion passengers on single operator ATVs. Suzuki has also made recommendations that the relevant state workplace legislation be amended by, amongst other things, inclusion of express references to ATVs in the definition of plant and equipment’ and by the introduction of ATV “operator safety standards” which would include a requirement that accredited ATV safety training be an integral part of farm safety management.

In addition, Suzuki's customers are provided with the most reliable and up to date information in relation to the safe operation of all of its vehicles. Suzuki promotes the safe and responsible use of ATVs through its involvement in the activities of the FCAI and by reference to information in its warning decals, owner manuals, websites and training, and by providing a free of charge ATV safety video to its customers.

Suzuki remains committed to developing and implementing practical strategies to ensure and improve the safety of ATVs and welcomes the opportunity to provide its comments in relation to the Public Discussion Paper on the review of design and engineering controls for improving ATV safety.

Based on the research conducted for and on behalf of the FCAI and SVIA to date, Suzuki does not support the fitment of ROPS or CPDs and believes that information, training, compliance and enforcement of proven safety measures (including mandatory wearing of helmets, appropriate use of ATVs and a ban for children under the age of 16 from operating adult-sized ATVs and the carrying of pillion passengers on single operator ATVs) is critical to improving the safety of ATVs riders. Suzuki will however continue to review and investigate engineering improvements where they can be proven to be safe an effective for its customers.

Suzuki also stresses the importance of analysing real injury and fatality data to understand the true causes of death and injury on ATVs. The data relied on in the Public Discussion Paper ought to be treated cautiously. As we understand it the data was derived by Media Monitors Australia by scanning daily, weekly and monthly media publications Australia wide utilising specific ATV and Quad Bike search terms. No criticism is made of Media Monitors in this regard however, this data ought to be treated more cautiously than the data produced by the National Coroners’ Information System (NCIS) (which only deals with fatalities and not injuries). It is only by properly understanding and analysing the real data that you can identify the true causes of deaths and injuries on ATVs and in turn continue to make them safer.

Response to questions identified in the Discussion Paper
1.  What design solutions and/or engineering controls could improve quad bike stability and safety?
Comment
There is no credible or proven research which supports any current design solution and/or engineering controls options that can improve ATVs stability and safety at this time. Suzuki supports the position that further research is required into any engineering improvements to ATVs to prove that such options can be safe and effective for ATVs.
It is important that the inherent design and intended use of ATVs is considered in carrying out the research required to determine appropriate design solutions or engineering controls which may assist in the stability and safety of ATVs. It is important to consider how changing the design or engineering components may affect its intended use and operating features.
ATVs are more akin to motorcycles in design and engineering controls. ATVs are used in off-road conditions, with uneven and unpredictable terrains (commonly used in the agricultural industry), where the ability to quickly change direction is vital. Rider control is critical to the intended use of the ATV with the position of the rider's body on the ATV critical to the effective operation, stability and safe use of the ATV. The focus is on the rider's ability to manoeuvre the ATV, with seats, handlebars, wheelbase and hand operated accelerator/brake/gears/clutch designed to ensure that the ATV rider movement is crucial to the operation of the ATV (known in the industry as "rider-active"). Therefore, commonly used designs and engineering controls which have been introduced to other types of vehicles which are not rider/driver-active (where manoeuvring of the body has not direct connection with the operation of the vehicle) in the automotive industry would not be suitable for use on ATVs based purely on the intended use of an ATV and its rider-active nature.
In relation to the suggested engineering controls in the Discussion Paper, we set out our position below:
·  lateral stability specification - There is no evidence that supports the proposition that lateral stability is a correct measure of ATV safety or any connection between roll overs in ATVs and lateral stability measures. In the US, it has been reported that the vast majority of ATV related deaths and injuries were due to rider/operator behaviour as the primary contributory factor whilst lateral stability was states to be a contributing factor in only a small minority of cases.
·  active stability controls - There is currently no active stability controls systems that are available for off-road vehicles. There is sensor technology, such as electronic stability controls (ESC), currently used in vehicles used on public road (i.e. "on-road" as opposed to "off-road" vehicles) which work on a traction control and/or anti-lock braking system. However, ATVs and similar off-road vehicles do not and cannot implement these types of controls/system required to enable ESC to be implemented. The two main reasons for this is that such systems increase tyre traction and reduce wheel spin leading to an decrease in the required mobility for use of an ATV and in roll stability for ATV.
·  passive stability control systems - There may be some limited safety enhancement in the use of ATVs. It is likely that any warning device would be triggered at a point where it is too late to alert ATV riders to potential roll over incidents (e.g. the ATV would already be on the incline of the slope when the warning device is triggered). ATV use in uneven and off-road terrain together with the speed at which ATVs are inherently built to achieve in these environments for effective operation, means that warning sounds may go off at incorrect times (i.e. bumpy terrain, increased vibrations), may not be heard (i.e. operating in noisy environments) and would be triggered too late for the rider to have enough time to react. A visual warning would only increase safety if it didn’t distract the rider from correctly operating the ATV.
·  increasing wheel track width and/or wheel base length - ATVs needs to be, by their nature, mobile and easy to manoeuvre with the rider's body weight. Increasing length and width on vehicles will make the vehicle more stable and heavier which are not features that are compatible with ATVs. It would transform an ATV into a different type of vehicle entirely, and other additions/changes in the current design and engineering controls on ATVs would need to be implemented (e.g. a steering wheel).
·  lowering the centre of gravity - The less ground clearance affects the mobility and utility of an ATV (which are its essential features). There are already ATVs available in the market with lower centres of gravity. However these types of ATVs would not be suitable for use by farmers /agricultural industry, primary use of ATVs, which requires vehicles that have higher ground clearance to deal with the environmental conditions.
A further issue with the implementation of design and engineering controls to enhance safety measures, is the ability for riders to modify, disable or remove these devices in the event that it detracts from the intended use and purpose of the purchased ATV.
The rider-active feature of ATVs makes it imperative that riders are aware of, trained and take control of their own safety measures. The simplest way to do this is to inform and enforce proven safety measures such as the mandatory wearing of helmets, comprehensive training on the appropriate use and operation of ATVs (which is currently offered by a number of companies within the industry) and promotion of the requirements and obligations of ATV riders set out in owner manuals. In addition to the promotion of the existing work place safety legislation and regulations.
There needs to be further work performed in relation to the enhancement, research and implementation and enforcement of these proven safety measures, in conjunction with further research in relation to options of effective design/engineering controls that could be utilised for ATV stability and safety.
2.  What engineering controls could improve operator protection in the event of a roll over?
Comment
If a rollover occurs, it is crucial that the ATV rider is not restricted in the ATV by additional hardware/equipment on the ATV. This is so the rider can separate from the ATV in a controlled way. ATVs are built and intended to be used for off-road and uneven terrain with an ability to quickly change direction to deal with this type of volatile environment. Any introduced or fitted engineering controls to ATVs need to have consideration of the inherent design of the ATVs, how and where the ATV is intended to be used. In addition to, being applicable to "rider-active" feature of the operation of an ATV.
There are simple proven safety measures and techniques which ATV riders should be informed of and forced to undertake which are proven to protect riders against injury from roll-overs. These include:
1.  The rider must place himself/herself in the correct riding position on the ATV for example, being "uphill" on slopes/hills or to the "inside" in corners/turns.
2.  Riders/operators/purchasers of ATVs should be required to undertake comprehensive training in relation to the design/use and requirements of operating a ATV. This should include that ATV riders are not to use ATV on terrain or in applications for which its is not suited.
3.  A helmet must be worn at all times operating a ATV.
4.  Read the owner's manual and watch the safety video provided with the ATV.
In relation to the engineering controls referred to in the Discussion Paper, Suzuki's position is as follows:
·  crush protection devices (CPD) - There has been much debate, particularly recently, on the utility of CPD/Roll Over Protective Structures (ROPS) being fitted to ATVs in an attempt to improve safety. There is no credible evidence or research that Suzuki is aware of globally that proves that ROPS will improve safety or avoid ATVs related injuries/fatalities. However, there is comprehensive reliable research that indicates that the fitment of ROPS/CPD to ATVs may increase the risk of injury to ATV riders (especially in the event of riders not wearing helmets). In particular, if a ATV rider is obstructed by the ROPS/CPD in the event of a roll over, it may create an environment whereby the rider/passenger is thrown up against the ROPS/CPD device. This is of considerable concern in relation to the safety of ATV riders, in particular, when it is currently not mandatory to wear helmets when operating ATV. It should be highlighted also that in carrying out this research it was shown that the least harmful of the ROPS/CPDs tested caused the same amount of injuries (approximately) as it prevented when tested with helmeted riders.
Internationally, there have been no ATVs designed to accept fitment of ROPS/CPDs, thus ROPS/CPDs are not acceptable safety mechanisms for ATVs.
Suzuki does not support the fitment of ROPS/CPDs to ATVs as an effective safety mechanism at this time. The fitment of these devices to ATVs may lead to more injuries than they will prevent. Suzuki is opposed to the use of ROPS/CPDs on ATVs because of international research which found that all ROPS/CPDs examined at the time posed an unacceptably high risk of creating new injuries (research conducted by Dynamic Research Inc in 2007). The research modelled several types of ATV overturns based on 113 real ATV accidents from the UK and USA, and compared unmodified and modified ATVs across a range of use and misuse conditions. The analysis used the relevant portions of international standard ISO 13232 (2005) for Motorcycles – Test and analysis procedures for research evaluation of rider crash protective devices fitted to motorcycles.